8900.1 CHG 240



Section 1  Conduct a Part 133 Base Inspection


Indicates new/changed information.

A.    Operations: 1616.

B.    Maintenance: 3627.

6-1372    OBJECTIVE. Determine whether an applicant meets Title 14 of the Code of Federal Regulations (14 CFR) part 133 regulatory requirements for initial certification, or whether an operator continues to be able to conduct operations in compliance with 14 CFR. Successful completion of this task results in either an indication of compliance or noncompliance in the applicant’s or operator’s file.

6-1373    GENERAL.

A.    Authority. Part 133, § 133.39 allows the Administrator to make the inspections and/or tests found necessary to ensure compliance with the regulations.

B.    Flight Under Instrument Flight Rules (IFR). If the operator cannot produce records showing they have a pilot who is instrument rated and current during a base inspection, then the operator should surrender authorization for flight under IFR or the assigned inspector should rescind it. The operator may retain the Operating Certificate for up to 2 years after discontinuing operations, but the operator may not retain IFR authorization without having a current IFR pilot and appropriately equipped rotorcraft. Use discretion. If the instrument pilot has temporarily lost currency, do not remove the IFR authorization.

C.    Operator Recordkeeping. The Administrator requires the operator to maintain records for the purposes of inspections and determining compliance with the regulations.

1)    For each class of authorization, the operator must maintain current pilot records signed by the Chief Pilot. These records should include the following:
a)    The rotorcraft classes each pilot is authorized to fly;
b)    A record of each pilot’s duty appointment, such as Chief or Assistant Chief Pilot, and the effective date of the appointment to each duty position;
c)    The dates each pilot was assigned to operate external loads and the dates each pilot was removed from an assignment;
d)    A copy of the appropriate logbook endorsements, letters of competency, or verification of a pilot’s passing a knowledge and skill test for the class of external load that pilot is assigned to; and
e)    A record of each pilot’s operational checks.
Indicates new/changed information.
2)    For Class D load operations, the operator must maintain the following records in addition to those listed above and signed by the Chief Pilot.
a)    A record for each pilot reflecting the date the pilot completed the initial or recurrent training; and
b)    A record for each pilot of currency within the past 12 months that specifies class load, make and model (M/M) of rotorcraft, and date of operations.
Indicates new/changed information.
3)    For flight under IFR, the operator must maintain the following records for each pilot in addition to those listed above.
a)    A list of assignments stating the class of load and M/M of rotorcraft each pilot is authorized to operate; and
b)    An IFR currency record, a copy of the logbook endorsement for 14 CFR part 61, § 61.57 instrument competency check, or a record of instrument currency obtained within the past 6 months.


A.    Coordination. When an Airworthiness inspector cannot attend the base inspection, an Operations inspector should tailor the inspection to examine general airworthiness aspects. In this case, schedule a complete airworthiness inspection as soon as practical after the base inspection.

Indicates new/changed information.

NOTE:  Airworthiness aviation safety inspectors (ASI) will conduct a ramp inspection per Volume 6, Chapter 1, Section 4.

Indicates new/changed information.
1)    The inspector should be prepared to conduct a general examination of equipment, including the attaching means, personnel lifting devices, and quick-release devices in the normal and emergency configurations.
2)    The inspector should observe actual operational checks performed by pilots, such as installing and removing attaching devices.
3)    The inspector must coordinate with the airworthiness unit to ensure followup inspection of any items outside of the inspector’s expertise.
Indicates new/changed information.

B.    Levels of Deficiency and Appropriate Corrective Action. This paragraph offers examples of various deficiencies that might occur in an inspection and the appropriate action to take for each situation. Two assumptions apply. First, even after finding a discrepancy, the base inspection is completed. After inspection, summarize deficiencies and recommended corrective actions in a note to the file and/or in remarks to the PTRS record. Secondly, an unsatisfactory report may call for an enforcement action. Unsatisfactory reports usually result from violations of certification or operating rules found during the inspection. The requirements for holding an external-load Operating Certificate are never less than those for initial certification. There are intermediate stages between satisfactory and unsatisfactory results that may result in a satisfactory inspection with corrective action.

Indicates new/changed information. Indicates new/changed information.
1)    A spot correction is a discrepancy that is not a violation and is corrected during the inspection. It may require no further action. For example, the inspector does not find a facsimile of the external-load Operating Certificate on board the rotorcraft. The corrective action is the inspector notifying the operator that the certificate is not in the rotorcraft. During the inspection, the operator makes a copy of the certificate and places it in the rotorcraft. The inspector takes no other corrective action because no external-load operation occurred without the certificate. However, the inspector marks the PTRS data sheet with an “I” to indicate informational discrepancies during the inspection, and note that no facsimile of the certificate was found upon inspection and that a spot correction was made.
2)    Take followup action on deficiencies or lack of pilot knowledge that do not involve violations. For example, at the time of inspection, a placard was missing from the rotorcraft and it was not readily available. However, there was no evidence that the rotorcraft operated without it. As a corrective action, advise the operator verbally of the deficiency, then write a letter to the operator outlining the discrepancy found during the inspection, make a copy of the letter for the Flight Standards District Office (FSDO) file, and schedule a followup inspection. Mark the PTRS data sheet with an “F” indicating followup.
Indicates new/changed information.
3)    A finding of “unsatisfactory” involves a blatant violation. For example, during an inspection, the inspector finds that a newly designated Chief Pilot has not completed the knowledge and skill test. The inspector must contact the previous Chief Pilot and obtain verbal and written statements, as well as a copy of the previous Chief Pilot’s last pay stub, that proves the Chief Pilot ceased serving as Chief Pilot more than 30 days before the last external-load operation conducted by the operator. (See Volume 7, Chapter 6, Section 1 and Federal Aviation Administration (FAA) Order 2150.3, FAA Compliance and Enforcement Program.)
Indicates new/changed information.

C.    Presence of Chief Pilot and Other Pilots at Inspection. It is desirable to be able to spot-check the knowledge of the Chief Pilot and other pilots of the operation. Spot-check examination of pilots to verify continuing compliance. For example, ask questions on the Rotorcraft-Load Combination Flight Manual (RLCFM), including Weight and Balance (W&B) problems and, if applicable, questions on the authorizations for Class D and/or IFR operations. In addition, ask the pilots to demonstrate the use of attaching means, the operation of normal and emergency release mechanisms, and the operation of the winch, as applicable. If as a result of an inspection or test, the pilot or operator’s competency is found questionable, take action under Title 49 of the United States Code (49 U.S.C.) § 44709 and/or enforcement action. (See Volume 7, Chapter 6, Section 1.)

D.    Discrepancy Between FSDO Files and Operations Base Files. If a discrepancy occurs between the records kept in the FSDO file and those found during the base inspection, determine which records are current and/or approved, and require correction of the unapproved or outdated ones. For example, the operator used a new rotorcraft without adding it to the list of authorized rotorcraft. The list is no longer current, and the inspector may initiate enforcement action to rectify the omission.

E.    An Expired Lease Agreement. The exclusive use agreement must be current.

6-1375    INITIAL CERTIFICATION VERSUS LATER SURVEILLANCE. When this task is performed as the base inspection for original certification (during the demonstration and inspection phase of the certification process), there are some items that cannot be inspected. For example, an applicant for an external-load Operating Certificate would not have certificate facsimiles or lists of authorized rotorcraft for examination. For an original certification, mark the “NA” column on the base inspection job aid (Figure 6-63, Part 133 Base Inspection Job Aid) for items the inspector cannot evaluate.


Indicates new/changed information.

A.    Prerequisites. This task requires knowledge of the regulatory requirements of part 133, FAA policies, and qualification as an ASI (Operations) with knowledge of external-load operations. For Airworthiness inspectors, the task requires experience as a rotorcraft mechanic. If a FSDO does not have inspectors with this experience, the office manager will designate the best qualified ASIs.

B.    Coordination. This task requires coordination with the airworthiness unit.


A.    References (current editions):

    Title 14 CFR Parts 1, 27, 29, 61, 91, and 133.

Indicates new/changed information.

    Advisory Circular (AC) 133-1, Rotorcraft External-Load Operations.

    PTRS Procedures Manual (PPM).

    FSDO file for this operator or applicant working file for initial certification.

B.    Forms. FAA Form 8710-4, Rotorcraft External-Load Operator Certificate Application (for renewal or amendment).

C.    Job Aids:

    Part 133 Base Inspection Job Aid (Figure 6-63).

    Sample letters and figures.

6-1378    PROCEDURES.

A.    Preinspection Activities.

1)    Open the PTRS record.
2)    Review the operator’s records file at the FSDO for currency and applicability of the following:
a)    Congested area plans (CAP),
b)    Minimum equipment lists (MEL),
c)    Training program (Class D only),
d)    RLCFM,
e)    Operating Certificate,
f)    List of authorized rotorcraft,
g)    Authorization(s) for Class D and IFR,
h)    Chief Pilot’s designation,
i)    Training records and evidence of knowledge and skill tests,
j)    Previous ramp inspections,
k)    Complaints,
l)    Operator’s and pilots’ violation histories,
m)    Operator’s and pilots’ accident/incident histories, and
n)    Associated records of surveillance.
3)    Schedule the base inspection.
a)    Schedule an appointment with the operator at the home base.
b)    Advise the operator to have the Chief Pilot and at least one other pilot available during inspection, if possible.
c)    Arrange to have at least the exclusive use rotorcraft available.
d)    Remind the operator that the rotorcraft logbooks and engineering data must be available at the inspection, if practicable.

B.    Conduct the Base Inspection.

1)    Inspect the following records to determine regulatory compliance:
a)    Ensure that the Operating Certificate and current authorizations are available for inspection. A copy must be on board each rotorcraft during part 133 operations. The original Operating Certificate and all facsimiles must be identical to the copy in the FSDO files.
b)    Inspect the list of authorized rotorcraft to ensure that it reflects the rotorcraft currently available for use and the authorized classes of load combination for each rotorcraft. A copy of this must be on board each rotorcraft during part 133 operations. This list and all copies of it must be identical to the most current version in the FSDO files.
c)    Examine the RLCFM of each rotorcraft for currency.
d)    Check to see that the operator has a current, approved Rotorcraft Flight Manual (RFM) for each rotorcraft.
e)    For a CAP, see Volume 3, Chapter 51, Section 6.
f)    Check for proof of ownership of the rotorcraft, or check the exclusive lease agreement or notes on the agreement for exclusivity of use. For leases, see Volume 3, Chapter 51, Section 5.
g)    Check for the appropriateness of external-load classification.
h)    Determine each pilot’s qualifications for the operation by examining the records of each pilot’s logbook endorsement or knowledge and skill letter of competence.
i)    For Class D, check the training program to see if there are any unapproved changes. Ensure that the program matches the one filed in the FSDO.
Indicates new/changed information.
j)    For an IFR authorization, check that at least one pilot is current for IFR rotorcraft operations and that at least one rotorcraft is certificated and equipped for flight under IFR (Airworthiness inspector coordination is required).
k)    Inspect the records of each pilot.

1.    For pilots with Class D authorization, check their records to ensure that initial or recurrent training (as appropriate) has been received within the preceding 12 calendar-months (§ 133.37(b)).

Indicates new/changed information.

2.    Pilots with Class D authorization who have performed a rotorcraft external-load operation of the same class and in an aircraft of the same type within the past 12 calendar-months need not undergo recurrent training (§ 133.37(c)).

2)    Spot-check any available external-load pilots. Examine the pilots verbally for competence in the following critical areas:
a)    Determine the pilots’ understanding of the operating limitations outlined in § 133.45.
b)    Determine the pilots’ knowledge of the special authorizations (Class D and/or IFR). For Class D operations, ask the pilots to calculate one-engine-inoperative (OEI) hover performance at a typical weight and altitude in accordance with § 133.45(e)(1).
c)    Ask the pilots to compute a W&B problem.
d)    Ask the pilots to compute fuel required for a mission. They must comply with part 91, § 91.151 or § 91.167.
Indicates new/changed information.
3)    Inspect the rotorcraft (Airworthiness inspector coordination is required).

C.    Observe an Onsite Operation. If possible, observe an actual external-load operation. Do not request that the operator conduct one unless one is scheduled.

D.    Satisfactory Examination Results.

1)    For an initial certification, indicate “satisfactory” on the base inspection job aid and the certification job aid. Proceed with the other demonstration and inspection phase inspections.
2)    For a renewal, complete the application, prepare and issue a new certificate, and make a copy of the certificate for the FSDO file. If there are any changes from the initial certification or previous renewal, make a copy of the most recent certificate and indicate the changes from that copy to the current one. Indicate “satisfactory” on the base inspection job aid.
Indicates new/changed information.
3)    For followup items, advise the operator verbally of the deficiency and, if necessary, write a letter to the operator outlining the discrepancies found during the inspection. (see Figure 6-64, Sample Letter Outlining Inspection Discrepancies). Schedule a followup inspection as appropriate.

E.    Unsatisfactory Examination Results.

Indicates new/changed information.
1)    Inform the operator that the inspection was unsatisfactory. Confirm the deficiencies encountered in writing (see Figure 6-65, Sample Letter Indicating Unsatisfactory Inspection).
2)    According to the severity of the problem, take one of the following actions:

    Schedule a followup inspection in 30 days; or

    Initiate an enforcement investigation. See Volume 7, Chapter 6, Section 1.

F.    Close the PTRS Record.

6-1379    TASK OUTCOMES. Completion of this task results in one or more of the following:

    A record indicating a satisfactory inspection.

    A record indicating an unsatisfactory inspection.

    A record on file indicating deficiencies found during inspection and corrected on the spot.

    A letter to the operator indicating any discrepancies found during inspection.


    Followup inspection with a change in frequency of the surveillance plan for unannounced inspection, and

    Reexamination of pilot by conducting knowledge and skill test, as necessary.

Indicates new/changed information.

Figure 6-63.  Part 133 Base Inspection Job Aid

Part 133 Base Inspection Job Aid



Inspector Initials





1.    Flight Standards District Office (FSDO) office file review.






2.    Application properly completed for renewal/amendment.






3.    Rotorcraft inspection.






a.    Equipped with a fixed external cargo‑carrying device for Class A loads.






b.    Equipped with a hook for Class B, C, or D loads.






c.    Equipped with a winch or other device.






d.    Title 14 CFR part 133, § 133.49(a) placard in the cabin stating the class or classes for which approval has been given, and weight/center of gravity (CG) limitations.






e.    Section 133.49(b) marking adjacent to the load-carrying device stating maximum load as per the Rotorcraft-Load Combination Flight Manual (RLCFM).






f.    Inspection of all rotorcraft:






(1)  Installation and function of the load‑carrying or load-attaching devices.






(2)  Optional equipment installations inspected.






4.    Operator has a copy of Advisory Circular (AC) 133-1, Rotorcraft External-Load Operations.






5.    Operator has pertinent 14 CFR parts for reference.






6.    RLCFMs approved and current.






a.    Ground crew briefings.






b.    All items required by § 133.47, Rotorcraft‑Load Combination Flight Manual.






Indicates new/changed information. Indicates new/changed information.

Figure 6-63.  Part 133 Base Inspection Job Aid (Continued)

Part 133 Base Inspection Job Aid



Inspector Initials





7.    Class D authorization.






a.    Authorization current and available for inspection.






b.    Personnel lifting device is FAA-approved.






c.    Training records for each pilot conducting Class D operations.






d.    Operator has use of suitable communications equipment.






e.    All pilots have conducted part 133 operations within the previous 12 months or must have recurrent training prior to conducting operations.






8.    Operator has appropriate Chief Pilot.






a.    All pilots passed knowledge test (§ 133.23(b)).






b.    All pilots passed skill test (§ 133.23(c)).






9.    Congested area operations conducted.






10.  Congested area plan (CAP) approved.






11.  Flightcrew knowledge:






a.    Understands operating limits in § 133.45.






b.    Understands passenger-carrying limitations.






c.    Able to compute weight and balance (W&B).






d.    Understands operating airspeed limit.






e.    Understands limitations concerning restricted category rotorcraft.






f.    Understands typical hand signals.






g.    Understands content of operator authorizations.






h.    Understands fuel planning, 14 CFR part 91, § 91.151.






Figure 6-63.  Part 133 Base Inspection Job Aid (Continued)

Part 133 Base Inspection Job Aid



Inspector Initials





12.  Operator has instrument flight rules (IFR) authorization.






a.    At least one pilot IFR rated and current in rotorcraft.






b.    At least one rotorcraft certified and equipped for IFR flight.






c.    Authorization current and available for inspection.






d.    Understands fuel planning, § 91.167.






13.  Rotorcraft external-load Operator Certificate available for inspection and current.






14.  List of authorized rotorcraft available for inspection and current.












Indicates new/changed information.

Figure 6-64.  Sample Letter Outlining Inspection Discrepancies

FAA Letterhead


[Operator’s name and address]

Dear [operator’s name]:

During an inspection of your facilities and equipment conducted on [date], we noted the following discrepancies:

[List specific discrepancies.]

[List discrepancies corrected during the inspection.]

You should correct the above items within 30 days of receipt of this letter. We scheduled a followup inspection for [time and date]. If you are unable to correct these discrepancies before the next inspection or have any questions, please contact this office.


[Signature of principal operations inspector (POI) or certification project manager (CPM)]

Indicates new/changed information.

Figure 6-65.  Sample Letter Indicating Unsatisfactory Inspection

FAA Letterhead


[Operator’s name and address]

Dear [operator’s name]:

The inspection of your facilities and equipment conducted on [date] was unsatisfactory.

We determined the following items were not in compliance with 14 CFR.

[List each specific item and the related 14 CFR, for example:]

[Pilot training records for [pilot’s name] did not indicate satisfactory completion of the appropriate knowledge and skill tests (14 CFR part 133, § 133.37).]

This matter is now under investigation by the FAA. We wish to offer you an opportunity to discuss the incident personally and submit a written statement. If you desire to do either, accomplish this within 10 days following receipt of this letter. Your statement should contain all pertinent facts and any extenuating or mitigating circumstances that you believe may have a bearing on the incident. If we do not hear from you within the specified time, we will process our report without the benefit of your statement.


[Signature of principal operations inspector (POI) or certification project manager (CPM)]

NOTE TO INSPECTORS: You may also use this letter as the Letter of Investigation (LOI) to initiate enforcement action against a certificated operator.

RESERVED. Paragraphs 6-1381 through 6-1395.